DAILY UPDATES FOR LONG TERM CARE FACILITIES
We are posting the latest updates, guidance and resources on this page on a daily basis. In addition to these daily updates, please access more information and resources on the following sub-pages:
EMResource - ISDH's COVID-19 PPE Inventory Tracking Tool
ISDH is asking you to update your PPE supplies daily in this tool so that resources can be distributed efficiently. Learn more.
APRIL 3, 2020
- ISDH COVID-19 Infection Control Webinar Scheduled for Friday, April 3, 2020 at 1 p.m. EST has been cancelled
- ?CMS Issues New Recommendations to Nursing Homes, State and Local Governments
- Nursing homes should immediately ensure that they are complying with all CMS and CDC guidance related to infection control, particularly focusing on consistent hand washing and changing and removing of PPE based on preliminary data from infection control focused surveys.
- FAQs - Alignment of Isolation Waivers, MDS, and Payment Policies
- Check this FAQ document to help providers navigate how the various CDC and CMS COVID-19 guidance and Section 1135 waivers interact with current MDS-RAI coding guidance and payment models in SNFs, specific to situations where it is determined that a resident requires isolation related to the COVID-19 virus. This guidance is intended to provide context to help guide provider decisions and will be updated as necessary as new government policies and guidance are issued.
APRIL 2, 2020
APRIL 1, 2020
ISDH Issues COVID-19 Guidance for Hospital Discharge to Long Term Care Facilities
Earlier this evening, the Indiana State Department of Health (ISDH) released COVID-19 guidance for hospital discharge to nursing facilities and skilled nursing facilities, and facilities sending of residents to the emergency department, which can be found in full here.
The guidance issued is substantially different from the original version provided to IHCA late last week. IHCA worked with ISDH and the Indiana Hospital Association to ensure there was an understanding of the current resource limitations and staffing challenges across long-term facilities, as well as the danger of introducing COVID-positive patients and PUIs into COVID-naive facilities.
IHCA also worked to improve the issued guidance to ensure the prioritization of local collaboration between the long term care facility and discharging hospital, the patient’s medical needs and goals for care, the facility’s ability to carry out isolation precautions, and the patient’s clinical status and available test results. Five patient categories were created to provide specific guidance to LTC facilities and hospitals.
The ISDH asks that this guidance be utilized when evaluating the transfer of a resident from the facility to the emergency department and of a patient from a hospital to a long term care facility.
If you have any questions regarding the guidance, please contact Zach Cattell (email@example.com) or Lori Davenport (firstname.lastname@example.org).
Requirements of Participation Waivers/ISDH Licensure Waivers/ Requested CMS Waivers
IHCA recognizes the myriad of waivers that have been issued by the federal and state governments are confusing to keep track of. The most recent waivers were issued by CMS and apply to the entire nation, called blanket waivers. The new waivers, which we reported on March 30th, were added to blanket waivers previously issued by CMS last week. The entire list of blanket waivers is here, and the LTC sections starts on page 9.
New CMS Waivers - Requirements of Participation
The new waivers addressed a variety of LTC Facilities Requirements of Participation and IHCA/INCAL has created a copy of the Requirements of Participation that clearly shows you the specific waived provisions with links between the provisions. Click here to access.
The list of impacted Requirements of Participation are:
- MDS submission timeframe
- PBJ reporting
- Physical Environment (for purposes of using currently non-certified buildings and areas of existing LTCs)
- Resident Groups (for purposes of promoting social distancing)
- Training and Certification of CNAs
- Physician Visits
- Resident Roommates and Groupings
- Resident Transfer and Discharge (very specific requirements here)
These new waivers were added to previously issued CMS blanket waivers concerning the 3-day stay and PASRR completion timeframes.
In addition, these are added to the CMS waivers obtained by the Indiana Family and Social Services Administration regarding a variety of Medicaid enrollment and payment provisions. You can read those on IHCA’s COVID-19 website.
ISDH Requests CMS Waivers - Requirements of Participation
In addition to the blanket waivers issued by CMS, ISDH Commissioner Kristina Box, M.D. submitted a request for more waivers of additional sections of the Requirements of Participation. The ISDH request was submitted on March 30th. Nearly all of the requests directly relate to state-level waivers that ISDH has issued in the past two weeks.
The list of requested waivers impact these Requirements of Participation:
- Non-permanent employees (for purposes of the Indiana Personal Care Aide program)
- Respect and dignity (to comply with visitation and gathering restrictions)
- Requirements for training of paid feeding assistance (for purposes of the Indiana waiver on feeding assistant training)
- Physician visits
- Physical environment (for purposes of using currently non-certified buildings and areas of existing LTCs)
- Resident Transfer and Discharge
The letter also included a request to waive many of the provisions that were included in the blanket waiver described above.
ISDH State-level Waivers and Orders
The ISDH has issued many state-level waivers and orders concerning comprehensive care licensure in the past two weeks and IHCA has reported on all of those. IHCA has created a chart of all of the ISDH state-level waivers for your reference. Click here to access.
CMS Call with Nursing Homes Today at 4:30 EDT
Please join the Centers for Medicare and Medicaid Services (CMS) on Wednesday, April 1st at 4:30 PM EDT for a COVID-19 Call with Nursing Homes. CMS leadership will provide updates on the agency’s latest guidance. There will be audience Q&A and an opportunity for you to share best practices with your peers. The call will be recorded if you are unable to join. Conference lines are limited, so you are highly encourage you to join via audio webcast, either on your computer or smartphone web browser.
Participant Dial-In: (877) 251-0301
Conference ID: 8395995
MARCH 31, 2020
CDC Update - Management of Patients with Confirmed COVID-19
This interim guidance is for clinicians caring for patients with confirmed infection with severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), the virus that causes coronavirus disease 2019 (COVID-19). CDC will update this interim guidance as more information becomes available.
ISDH COVID-19 Infection Control Webinar [CANCELLED]
Friday, April 3, 2020 at 1 p.m. EST
Assisted Living and Home-Based Residential Groups
Join ISDH presenters for a one-hour education and Q&A session on infection control practices for professionals in home-based, residential settings that serve all age groups. Assuming no technical difficulties, it is anticipated that this presentation will be recorded for later viewing.
Please use this link to join the meeting
Presented by: Indiana State Department of Health COVID-19 Response Team Members
Jennifer Spivey, MSN, RN, CNOR, CIC®, FAPIC
Infection Preventionist, ISDH
Deanna Paddack, RN
Chief Nurse Consultant, ISDH
Dan Rusyniak, MD
Chief Medical Officer, Indiana FSSA
Phone number: (415) 655-0001
Meeting access code: 477 815 926
MARCH 30, 2020
CMS Issues Blanket Regulatory Waivers
CMS has issued several blanket waivers for long term care providers in pages 9-12. The following blanket waivers are in effect, with a retroactive effective date of March 1, 2020 through the end of the emergency declaration. Full summary of the waivers is available here.
Governor Eric Holcomb Issues Executive Order 20-13
Relevant provisions of the executive order are summarized below:
- In the event the ISDH Commissioner determines patient capacity at any or all of Indiana’s hospitals exceeds what is available or needed, the EO permits the ISDH Commissioner to direct the opening, staffing, equipping, and use of a temporary facility for patient care. Access the full summary here.
MARCH 28, 2020
On-Boarding Employees Fingerprinting - Clarifying Guidance for Comprehensive Care Facilities
C § 16-28-13-4(a) (“Criminal History of Nurse Aides and Other Unlicensed Employees”) provides:
(a) Except as provided in subsection (b), a person who:
(1) operates or administers a health care facility; or
(2) operates an entity in the business of contracting to provide nurse aides or other unlicensed employees for a health care facility;
shall apply within three (3) business days from the date a person is employed as nurse aide or other unlicensed employee for a copy of the person's state nurse aide registry report from the state department and a limited criminal history from the Indiana central repository for criminal history information under IC 10-13-3 or another source allowed by law.
This statute requires that the facility owner or staffing agency “apply” for the limited criminal history, but not that the requested report actually be obtained. All ISDH requires as proof of compliance is documentation that a facility has applied for either the limited criminal history or the more extensive fingerprint-based history available through the Indiana State Police.
This guidance does not affect or relax the requirements of IC 16-28-13-3 (“Crimes barring employment at certain health care facilities”) or 42 CFR §483.12(a) (“Freedom from abuse, neglect, and exploitation”).
Personal Care Aide - Procedure Card
The Personal Care Aide (PCA) position provides staff that are trained in specific duties. The PCA PROCEDURE CARD has been develop to assist the PCA and other staff in identifying the procedures the PCA is trained to perform.
ISDH Issues 4th Waiver for Comprehensive Care
The Indiana State Department of Health released a waiver for comprehensive care facilities to provide services in alternative settings, perform emergency remodels and structural changes, perform emergency bed changes, and waived access and visitation rights (410 IAC 16.2-3.1-8). Each are described briefly below:
- Care in alternative settings. This waiver is intended to help implement the recently approved 1135 waiver granted by CMS so that care can be rendered to a resident regardless of the bed certification type and be provided in a unlicensed space in the same facility or in a different facility not licensed to provide skilled nursing care. These waivers are for licensing and regulation and to dot directly speak to payment, however IHCA understand that Indiana Medicaid is working on those matters as well. To obtain approval for either of these alternatives a comprehensive care facility should email Matt Foster, Brenda Buroker, Tammy Alley or Miriam Buffington an email that states:
- The facility has “declared a COVID-19 facility emergency";
- Will render care and required services to a resident in the facility, but in a bed that is not certified for the reimbursement program the resident is enrolled in (i.e. rendering care for a Medicaid patient in a Medicare only bed); or
- Will render care and required services to a resident relocated to an unlicensed space within the facility or in a different facility not licensed to provide skilled nursing care with the following information (1) immediate notice of the details of the relocation (resident name, new location, expected length of relocation); (2) that the relocation facility continues to meet all the resident’s care and safety needs; and (3) the facility notifies ISDH when the resident returns to their prior room or to a different room in the licensed space.
The ISDH would prefer to know about use of either of these options ahead of time. A facility can declare and notify the ISDH as soon as possible, particularly to prepare for coming needs. These actions also need to be taken in context of other regulations both still in effect and waived, such as the waiver for transfer and discharge that still require notice before the transfer and discharge but can be done so immediately rather than with 30 days notice.
- Remodels and structural changes. ISDH is waiving certain application fees, notice and approvals for remodels and structural changes under 410 IAC 16.2-3.1-2(d) so long as no later than three days after the completion certain notices are given and drawings are provided. Temporary approval with retroactive effect is also offered in the waiver. Certain procedures also come into play depending on whether the facility desires to make the change permanent or not.
- Emergency bed changes. ISDH is waiving certain application fees, notice and approvals for certain bed changes under 410 IAC 16.2-3.1-2(e) provided notice is given and a drawing and narrative of the bed change that has occurred or will occur is provided. Temporary approval with retroactive effect is also offered in the waiver. Some bed changes may be made permanent under certain circumstances, but will also be reviewed in context of applicable law (circumvention of the CON laws will not be permitted).
- Access and visitation rights. 410 IAC 16.2-3.1-8 has been waived so to comply with CMS and ISDH guidance to restrict visitors to long term care facilities.
There are certain to be questions about how the first three waivers above will work in practice. Please contact Zach Cattell at email@example.com with questions.
Personal Care Attendant (PCA) - Registry Spreadsheet
The Indiana State Department of Health (ISDH) Division of Long Term Care and the Nurse Aide Registry is requesting that following the successful completion of PCA training the linked spreadsheet below be used to submit the new PCAs name to the registry. The spreadsheet should then be emailed to: firstname.lastname@example.org
Access Personal Care Attendant (PCA) - Registry Spreadsheet here.
COVID-19 and Issues with Postal Carriers and Mail Delivery
Getting mail is one of the primary ways for our residents to stay connected to loved ones as well as to continue their important everyday routines. We have been made aware by several of our provider members about issues with mail delivery during the COVID-19 pandemic. Specifically, we have been hearing that postal carriers are refusing to comply with screening process as required by CMS and many states for entrance into long term care facilities.
The United States Postal Service (USPS) will be offering centers and other customers three options for mail delivery if there are issues with their current delivery.
- You may opt to redirect to a temporary mail receptacle inside or outside the building where screening would not be necessary.
- Place the mail on hold at the Post Office servicing this delivery. Mail and parcels can be held up to 30 days and will be available for customer pickup.
- Redirect all mail for the business to an alternate location.
We will continue to monitor this issue, and keep members apprised of any relevant updates.
MARCH 26, 2020
[ALL MEMBER WEBINAR] Operationalizing CMS's Infection Control Protocol - Handouts
Thank you to all who participated in our all-member webinar today afternoon. Please access the webinar presentation and other hand outs at the links below. The webinar recording can be accessed at here. Please note: CEUs are not eligible for viewing the recording.
Child Care Resources
IHCA/INCAL engaged the Indiana Family and Social Services Administration Office of Early Childhood and Out of School Learning (OECOSL) regarding available child care options and supports for our workforce and their children. There are two main options:
- The OECOSL can work with employers to establish “pop-up” child care for any facility, in partnership with Early Learning Indiana and resources in your local area. This opportunity may permit employers to pay for all of the child care facility directly for use by employees and children or partner to establish new child care options for employees to access with their own resources. Daycare options can be set up rapidly – within days to a week.
- Another option offered by the OECOSL is by engaging their team to scout out open slots at existing daycare centers in areas of need to then generate a list of availability that employer can provide to employees.
For assistance with either of these options contact Nicole Norvell, Director, Office of Early Childhood and Out of School Learning, 317.234.3313 or Nicole.Norvell@fssa.IN.gov.